IR 05000373/2002006

IR 05000373-02-006, IR 05000374-02-006, on 10/01 - 12/28/2002, Exelon Generation Company, LLC; LaSalle County Station, Units 1 & 2. Event Followup

ML030280404
Person / Time
Site:	LaSalle
Issue date:	01/24/2003
From:	Burgess B NRC/RGN-III/DRP/RPB2
To:	Skolds J Exelon Generation Co, Exelon Nuclear
References
IR-02-006
Download: ML030280404 (38)

Text

ary 24, 2003

SUBJECT:

LASALLE COUNTY STATION, UNITS 1 AND 2 NRC INTEGRATED INSPECTION REPORT 50-373/02-06; 50-374/02-06

Dear Mr. Skolds:

On December 28, 2002, the U.S. Nuclear Regulatory Commission (NRC) completed an integrated inspection at your LaSalle County Station, Units 1 and 2. The enclosed report documents the inspection findings which were discussed on January 3, 2003, with Mr. G. Barnes and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

Since the terrorist attacks on September 11, 2001, the NRC has issued two Orders (dated February 25, 2002, and January 7, 2003) and several threat advisories to licensees of commercial power reactors to strengthen licensee capabilities, improve security force readiness, and enhance access authorization. The NRC also issued Temporary Instruction 2515/148 on August 28, 2002, that provided guidance to inspectors to audit and inspect licensee implementation of the interim compensatory measures (ICMs) required by the February 25th Order. Phase 1 of TI 2515/148 was completed at all commercial nuclear power plants during calendar year (CY) 02, and the remaining inspections are scheduled for completion in CY 03. Additionally, table-top security drills were conducted at several licensees to evaluate the impact of expanded adversary characteristics and the ICMs on licensee protection and mitigative strategies. Information gained and discrepancies identified during the audits and drills were reviewed and dispositioned by the Office of Nuclear Security and Incident Response. For CY 03, the NRC will continue to monitor overall safeguards and security controls, conduct inspections, and resume force-on-force exercises at selected power plants.

Should threat conditions change, the NRC may issue additional Orders, advisories, and temporary instructions to ensure adequate safety is being maintained at all commercial power reactors.

Based on the results of this inspection, one self-revealing finding of very low safety significance (Green) was identified which was determined to involve a violation of NRC requirements.

However, because of the very low safety significance and because it was entered into your corrective action program, the NRC is treating this finding as a non-cited violation (NCV) consistent with Section VI.A of the NRC Enforcement Policy. Additionally, one licensee identified violation is listed in Section 4OA7 of this report. If you contest any NCV in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission - Region III, 801 Warrenville Road, Lisle, IL 60532-4351; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the Resident Inspector Office at LaSalle County Station.

In accordance with 10 CFR 2.790 of the NRCs "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Bruce L. Burgess, Chief Branch 2 Division of Reactor Projects Docket Nos. 50-373; 50-374 License Nos. NPF-11; NPF-18

Enclosure:

Inspection Report 50-373/02-06; 50-374/02-06 See Attached Distribution DOCUMENT NAME: C:\ORPCheckout\FileNET\ML030280404.wpd To receive a copy of this document, indicate in the box: "C" = Copy without attachment/enclosure "E" = Copy with attachment/enclosure "N" = No copy OFFICE RIII RIII RIII RIII NAME GWright/trn BBurgess DATE 01/23/03 01/24/03 OFFICIAL RECORD COPY

REGION III==

Docket Nos: 50-373; 50-374 License Nos: NPF-11; NPF-18 Report No: 50-373/02-06; 50-374/02-06 Licensee: Exelon Generation Company Facility: LaSalle County Station, Units 1 and 2 Location: 2601 N. 21st Road Marseilles, IL 61341 Dates: October 1 through December 28, 2002 Inspectors: E. Duncan, Senior Resident Inspector D. Eskins, Resident Inspector D. Jones, Reactor Engineer M. Mitchell, Radiation Specialist W. Slawinski, Senior Radiation Specialist D. Wrona, Reactor Engineer J. Yesinowski, Illinois Department of Nuclear Safety Approved by: Bruce L. Burgess, Chief Branch 2 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000373-02-06, IR 05000374-02-06; Exelon; on 10/01-12/28/02; LaSalle County Station;

Units 1 & 2. Event Followup.

This report covers a 3-month period of baseline resident inspection and announced baseline inspections on access control, radioactive material processing and shipping, and inservice inspection. The inspection was conducted by the LaSalle resident inspectors and Division of Reactor Safety (DRS) specialist inspectors. One Green finding was identified which was the subject of a Non-Cited Violation. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609 Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.

A. Inspector-Identified and Self-Revealing Findings

Cornerstone: Initiating Events, Mitigating Systems, Barrier Integrity, and

Emergency Preparedness

Green.

Licensee personnel inadvertently placed Unit 2 in a prohibited region of the power-to-flow map during a control rod maneuver on November 10, 2002. Entry into this region increased the likelihood of power oscillations.

The issue was of very low safety significance since no actual power oscillations occurred and the region was exited promptly after the condition was identified. A violation of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, was identified since this condition had occurred previously, but had not been identified.

(Section 4OA3)

B. Licensee-Identified Violation One violation of very low safety significance which was identified by the licensee has been reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensees corrective action program. This violation and corrective action tracking number is listed in Section 4OA7 of this report.

REPORT DETAILS

Summary of Plant Status

Unit 1 operated at or near full power until November 4, when power was reduced to about 77 percent to repair an electro-hydraulic control (EHC) leak on the #1 turbine stop valve emergency trip system oil line. Repairs were completed and Unit 1 was returned to full power on November 5, 2002. Unit 1 operated at full power until November 18 when power was reduced to about 77 percent in response to a feedwater heater transient and then reduced to about 70 percent the next day in response to a second transient. Repairs were completed and Unit 1 was returned to full power on November 21, 2002. Unit 1 operated at or near full power for the remainder of the inspection period, except for power reductions to perform pre-planned maintenance and surveillance testing activities, and rod pattern adjustments.

Unit 2 operated at or near full power until October 25, 2002 when the unit was shut down to accomplish LaSalle Maintenance Outage L2P02. All scheduled work was completed and Unit 2 was restarted on November 2, 2002. The unit was shut down shortly after going critical due to problems encountered while placing the turning gear on the main turbine. The turning gear problem was repaired, Unit 2 was restarted and synchronized to the grid on November 5, and returned to full power on November 11. Unit 2 operated at or near full power for the remainder of the inspection period, except for power reductions to perform pre-planned maintenance and surveillance testing activities, and rod pattern adjustments.

REACTOR SAFETY

Cornerstone: Initiating Events, Mitigating Systems, Barrier Integrity, and

Emergency Preparedness

1R01 Adverse Weather Protection

a. Inspection Scope

The inspectors reviewed the following systems to verify that the design features and licensee procedures protecting Unit 1 and Unit 2 systems from the effects of low temperature during the winter season were adequate. The inspectors focused on the following:

Condensate Storage Tank (CST) heaters and heat tracing; Control Room Ventilation (VC) heating; Lake Screen House (LSH) heating; Emergency Diesel Generator (EDG) room heating; Auxiliary Electric Equipment Room (AEER) Ventilation (VE) heating; and Essential Switchgear Room (VX) heating.

For these areas, the inspectors reviewed LaSalle Operating Surveillance (LOS) ZZ-A2, Preparation for Winter/Summer Operation, Revision 24. The inspectors walked down portions of the systems listed above to verify that the systems had been properly aligned for cold weather operation.

b. Findings

No findings of significance were identified.

1R04 Equipment Alignment

a. Inspection Scope

The inspectors performed partial walkdowns of accessible portions of trains of risk-significant mitigating systems during times when the trains were of increased importance due to the redundant trains or other related equipment being unavailable.

The inspectors utilized the valve and electric breaker checklists listed at the end of this report to verify that the components were properly positioned and that support systems were lined up as needed. The inspectors also examined the material condition of the components and observed operating parameters of equipment to verify that there were no obvious deficiencies. The inspectors reviewed outstanding work orders and condition reports (CRs) associated with the trains to verify that those documents did not reveal issues that could affect train function. The inspectors used the information in the appropriate sections of the Updated Final Safety Analysis Report (UFSAR) to determine the functional requirements of the systems.

The inspectors verified the alignment of the following trains with the Unit 2 A RHR sub-system unavailable due to planned maintenance:

Unit 2 B and C Residual Heat Removal (RHR) sub-systems; Unit 2 B Residual Heat Removal Service Water (RHRSW) sub-system; and Unit 2 High Pressure Core Spray (HPCS) system on December 2, 2002.

b. Findings

No findings of significance were identified.

1R08 Inservice Inspection (ISI) Activities

a. Inspection Scope

The inspectors conducted a review of the licensees inservice inspection program for monitoring degradation of the reactor coolant system boundary and the risk significant piping system boundaries. Specifically, the inspectors conducted a record review of the following examinations performed during the Unit 1 Refueling Outage during January 10 through February 4, 2002 (L1R09):

Weld Number System Nondestructive Testing Type 1-NIR-2B Reactor Pressure Vessel (RPV) Ultrasonic 1-NIR-2D Reactor Pressure Vessel (RPV) Ultrasonic 1FW-1001-71A Feedwater (FW) Ultrasonic/Magnetic Particle IRI-1001-05 Reactor Core Isolation Cooling Ultrasonic IRR-1055-13 Reactor Recirculation (RR) Ultrasonic/Liquid Penetrant These examinations were evaluated for compliance with the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code requirements. The inspectors also reviewed inservice inspection procedures, personnel certifications, and NIS-2 forms for Code repairs performed during the Unit 1 outage to confirm that ASME Code requirements were met.

The inspectors also reviewed a sample of inservice inspection related problems documented in the licensees corrective action program, to assess conformance with 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, requirements. In addition, the inspectors verified that operating experience was correctly assessed for applicability by the ISI group.

b. Findings

No findings of significance were identified.

1R11 Licensed Operator Requalification

a. Inspection Scope

On October 10, 2002, the inspectors observed two licensed operator re-qualification training scenario:

ESG50, CRD [Control Rod Drive] FCV [Flow Control Valve] Setpoint Failure/TDRFP [Turbine-Driven Reactor Feedwater Pump] Turbine Lube Oil Leak/Heater String Isolation/Loss of Stator Cooling/5-Rod ATWS [Anticipated Transient Without Scram]; and ESG47, RWLCS [Reactor Water Level Control System] Trouble/Loss of RPS

[Reactor Protection System] A/APRM [Average Power Range Monitor] C Failure/Loss of Both RR [Reactor Recirculation] Pumps/Failure to Automatic Scram/K SRV [Safety Relief Valve] Leakage/RHR [Residual Heat Removal]

Heat Exchanger Tube Rupture.

The inspectors observed operator actions to assess crew performance in terms of clarity and formality of communication; the ability to take timely action in the safe direction; the prioritizing, interpreting, and verifying of alarms; the correct use and implementation of procedures, including alarm response procedures; timely control board operation and manipulation, including high-risk operator actions; the oversight and direction by the shift manager, including the ability to identify and implement appropriate Technical Specification actions such as reporting and emergency plan actions and notifications; and the group dynamics.

b. Findings

No findings of significance were identified.

1R13 Maintenance Risk Assessment and Emergent Work Evaluation

a. Inspection Scope

The inspectors reviewed the licensees evaluation of plant risk, scheduling, configuration control, and performance of maintenance associated with planned and emergent work activities to verify that scheduled and emergent work activities were adequately managed. In particular, the inspectors reviewed the licensees program for conducting maintenance risk safety assessments and verified that the licensees planning, risk management tools, and the assessment and management of online risk was adequate.

The inspectors also assessed the licensee actions to address increased online risk during these periods, such as establishing compensatory actions, minimizing the duration of the activity, obtaining appropriate management approval, and informing appropriate plant staff, were accomplished when online risk was increased due to maintenance on risk-significant structures, systems and components (SSCs). The following specific activities were reviewed:

• Maintenance risk assessment for work planned during the week of September 29, 2002.

• Maintenance risk assessment for work planned during the week of October 6, 2002.

• Maintenance risk assessment for work planned during the week of October 13, 2002.

• Maintenance risk assessment for work planned during the week of November 3, 2002.

• Maintenance risk assessment for work planned during the week of December 8, 2002.

b. Findings

No findings of significance were identified.

1R14 Non-Routine Evolutions

.1 Unexpected Loss of Voltage Regulating Transformer 2APD7E

a. Inspection Scope

The inspectors reviewed the stations response to an unexpected loss of voltage regulating transformer 2APD7E on October 8, 2002, which rendered the B main control room and auxiliary electrical equipment room ventilation (VC/VE) systems inoperable. This transformer failure was identified by a non-licensed operator on routine rounds who noted a strong acrid odor in the vicinity of the transformer panel. In particular, the inspectors verified that operations response was appropriate for the event and in accordance with plant procedures. The inspectors reviewed the licensees plans, procedures, briefings, and contingency plans associated with the restoration of the transformer. Relevant schematics were also reviewed to verify that all equipment impacted by the loss of the transformer had been properly identified.

b. Findings

No findings of significance were identified.

.2 Unit 2B Emergency Diesel Generator (EDG) Voltage Regulator Replacement

a. Inspection Scope

The inspectors reviewed the stations response to an unexpected failure of the 2B EDG voltage regulator identified during High Pressure Core Spray (HPCS) system post-maintenance testing. The inspectors reviewed the activities associated with the voltage regulator replacement, establishing initial regulator settings, the Infrequently Performed Activity (IPA) briefing, and post-maintenance testing conducted in accordance with LaSalle Special Test (LST) 2002-034, 2B Diesel Generator Voltage Regulator PMT [Post-Maintenance Test], Revision 0.

b. Findings

No findings of significance were identified.

.3 Unit 2 Fuel Sipping

The inspectors observed Unit 2 fuel sipping operations conducted to identify leaking fuel on Unit 2. In particular, the inspectors verified that the sipping equipment was installed and operated in accordance with LaSalle Fuel Procedure (LFP) 400-6, Installation and Operation of Sipping Equipment.

b. Findings

No findings of significance were identified.

1R15 Operability Evaluations

a. Inspection Scope

The inspectors reviewed selected Operability Evaluations (OEs) and Engineering Changes (ECs) of degraded and non-conforming conditions affecting mitigating systems and barrier integrity to ensure that operability was properly justified and the component or system remained available, such that no unrecognized increase in risk had occurred.

The following evaluations were reviewed:

• OE02-12 Unit 1 Turbine Control Valve (TCV) #1 Foreign Material

• EC339629 Unit 2 Safety Relief Valve (SRV) Piping Supports Pinned

• OE02-04 Revision 1: Unit 1 Main Steam Isolation Valve Limit Switch Temperatures

b. Findings

No findings of significance were identified.

1R16 Operator Workarounds (OWAs)

.1 Routine Operator Workaround Review

a. Inspection Scope

The inspectors reviewed Operator Challenges (OCs) to identify any potentially adverse impact on the function of mitigating systems or the ability to implement an abnormal or emergency operating procedure. The following item was reviewed:

• OC 238: Emergency Diesel Generator Relief Valve Sticking

b. Findings

No findings of significance were identified.

.2 Operator Workaround Cumulative Effects Assessment

a. Inspection Scope

The inspectors reviewed the cumulative effects of all documented OWAs and OCs on reliability, availability, and potential for mis-operation of a system; the cumulative effects of operator workarounds that could affect multiple mitigating systems; and the ability of operators to respond in a correct and timely manner to plant transients and accidents.

b. Findings

No findings of significance were identified.

1R19 Post-Maintenance Testing

a. Inspection Scope

The inspectors reviewed and observed the following post-maintenance testing activities involving risk significant equipment associated with the following work orders (WOs):

• WO 00468913 Replace Unit 2 Division 2 125 Volt Direct Current (VDC)

Battery Cell 9 and Battery Cell 23 The inspectors observed post-maintenance testing and reviewed the test procedure to verify that the test was adequate for the scope of the maintenance work which had been performed and that the testing acceptance criteria was clear and demonstrated operational readiness consistent with the design and licensing basis documents. The observations and reviews were also conducted to verify that the impact of the testing had been properly characterized during the pre-job briefing; the test was performed as written and all testing prerequisites were satisfied; and that the test data was complete, appropriately verified, and met the requirements of the testing procedure. The inspectors also observed or reviewed post testing conditions to verify that the test equipment was removed, and that the equipment was returned to a condition in which it could perform its safety function.

b. Findings

No findings of significance were identified.

1R20 Refueling and Outage Activities

a. Inspection Scope

The inspectors observed the performance of LaSalle Unit 2 Maintenance Outage L2P02 and evaluated licensee outage activities to ensure that the licensee considered risk in developing the outage schedule; adhered to administrative risk reduction methodologies developed to control plant configuration; developed mitigation strategies for losses of key safety functions; and adhered to the operating license and Technical Specification requirements that ensured defense-in-depth. The following specific outage-related activities were accomplished:

• Outage Plan Review The inspectors reviewed the licensees outage control plan to verify that the licensee had appropriately considered risk, industry experience, and previous site-specific problems. The inspectors also confirmed that contingency plans for losses of key safety functions had been established.

• Monitoring of Shutdown Activities The inspectors observed the Unit 2 shutdown to Maintenance Outage L2P02 to verify that the plant was operated in accordance with regulatory requirements and plant procedures, in particular, that cool-down restrictions were followed.

• Licensee Control of Outage Activities The inspectors reviewed the licensees management of equipment during the outage to ensure that a defense-in-depth commensurate with the outage risk plan for key safety functions and applicable Technical Specifications was maintained. The reviews also served to verified that outage activities were appropriately managed. In particular, out-of-service activities were reviewed to ensure that tags were properly hung to support the out-of-service. Reactor coolant system instrumentation was verified to be configured to provide adequate indication of reactor vessel pressure, temperature, and level. In addition, the inspectors routinely observed decay heat removal system parameters to verify that decay heat removal systems were functioning properly.

The inspectors monitored flow paths, configurations, and alternative means for inventory addition and decay heat removal to ensure they were consistent with the outage risk plan. The inspectors reviewed the licensees control of reactivity and secondary containment to ensure they were in accordance with Technical Specifications.

• Refueling Activities The inspectors observed fuel handling operations to verify they were conducted in accordance with Technical Specifications and approved procedures, and that the location of fuel assemblies was tracked from core offload through core reload.

• Monitoring of Heatup and Startup Activities The inspectors reviewed Technical Specifications, license conditions, and other prerequisites, commitments, and administrative procedure prerequisites for mode changes to ensure they were met prior to changing modes or plant configurations. The inspectors conducted a walkdown of containment prior to restart to verify that debris had not been left which could adversely impact the Emergency Core Cooling System (ECCS) suction strainers.

• Identification and Resolution of Problems The inspectors reviewed the licensees identification of problems related to refueling outage activities to ensure they were identified at an appropriate threshold and that they were entered into the corrective action program.

b. Findings

No findings of significance were identified.

1R22 Surveillance Testing

a. Inspection Scope

The inspectors observed surveillance testing on risk-significant equipment to verify that the SSCs selected were capable of performing their intended safety function and that the surveillance tests satisfied the requirements contained in Technical Specifications, the Updated Final Safety Analysis Report (UFSAR), and licensee procedures. The surveillance testing observations were also conducted to verify that the test was adequate to demonstrate operational readiness consistent with design and licensing basis documents, and that the testing acceptance criteria was clear. The reviews and observations also served to verify that the impact of the testing had been properly characterized during the pre-job briefing; the test was performed as written and all testing prerequisites were satisfied; the test data was complete, appropriately verified, and met the requirements of the testing procedure; and that the test equipment range and accuracy was consistent with the application, and the calibration was current.

Observations following the completion of the test were used to verify that the test equipment was removed, and that the equipment was returned to a condition in which it could perform its safety function.

The following surveillance testing activities were observed:

• LOS-DG-M2, Attachment 2A, 2A Diesel Generator Operability Test - Idle Start

• LaSalle Technical Surveillance (LTS) 200-19, Attachment B, ECCS [Emergency Core Cooling System] Cubicle Area Cooler Flowrate Test - HPCS [High Pressure Core Spray] Pump Room Area Cooler Fan 2VY02C

b. Findings

Introduction One Unresolved Item (URI) was identified associated with the identification of screws missing from the Unit 2 Division 3 High Pressure Core Spray (HPCS) system area cooler, the Unit 2 Division 2 B/C Residual Heat Removal (RHR) system area cooler, and the Unit 1 Division 2 B/C RHR system area cooler, which potentially impacted the ability of these systems to perform their safety function.

Description On November 21, 2002, the inspectors observed LTS 200-19, ECCS [Emergency Core Cooling System] Cubicle Area Cooler Flowrate Test, Attachment B, Test HPCS [High Pressure Core Spray] Pump Room Area Cooler Fan 2VY02C. This surveillance consisted of a visual inspection of the Unit 2 HPCS area cooler with the system shut down followed by a flow rate test with the system running.

Following the completion of the visual inspection portion of the surveillance by engineering personnel, the inspectors independently reviewed the material condition of the area cooler. During that review, the inspectors identified numerous fasteners (screws) missing from the cooler internal framework. On November 22, engineering personnel determined that the function of these fasteners was to attach the cooler tubesheet to the cooler frame to prevent damage to the cooler during a seismic event.

Due to the large number of missing fasteners (33 of 48), the Unit 2 HPCS system was declared inoperable and an Emergency Notification System (ENS) notification was made in accordance with 10 CFR 50.72 for a loss of an accident mitigation function.

The fasteners were installed, followed by an extent of condition review on November 23.

That review identified similar issues with the Unit 2 Division 2 area cooler (no screws installed) and the Unit 1 Division 2 area cooler (15 of 48 screws missing). These coolers were promptly repaired and a supplement to the original ENS notification was made.

To determine whether the affected area coolers would have been actually impacted in the event of a design basis earthquake, the licensee performed a more in-depth engineering analysis than that which was accomplished as part of their prompt operability review. At the end of the inspection period, the results of this analysis were still pending. As a result, this issue is considered an Unresolved Item (50-373/0206-01(DRP); 50-374/0206-01(DRP)) pending a review of these engineering analysis results.

1EP4 Emergency Action Level and Emergency Plan Changes

a. Inspection Scope

The inspector reviewed Revisions 11, 12, and 13 of the LaSalle Station Annex to Exelons Standardized Emergency Plan to determine whether changes identified reduced the effectiveness of the licensees emergency planning, pending onsite inspection of the implementation of these changes.

b. Findings

No findings of significance were identified.

RADIATION SAFETY

Cornerstone: Occupational Radiation Safety

2OS1 Access Control to Radiologically Significant Areas (71121.01)

.1 Plant Walkdowns

a. Inspection Scope

The inspectors reviewed the radiological conditions of work areas within radiation areas and high radiation areas in the Auxiliary and Radwaste Buildings. The inspectors performed walkdowns and reviewed licensee controls to determine if the controls (i.e., surveys, postings, and barricades) were adequate to meet the requirements of 10 CFR Part 20 and the licensees Technical Specifications. Additionally, the inspectors reviewed the licensees practices during the last refueling outage for controlling access to contaminated areas and for declaring airborne contamination areas to determine if controls were acceptable.

b. Findings

No findings of significance were identified.

Cornerstone: Public Radiation Safety

2PS2 Radioactive Material Processing and Transportation (71122.02)

.1 Walkdown of Radioactive Waste Systems

a. Inspection Scope

The inspectors reviewed the liquid and solid radioactive waste system description in the UFSAR and the most recent information regarding the types and amounts of radioactive waste generated and disposed. The inspectors performed walkdowns of the liquid and solid radwaste processing systems to verify that the systems agreed with the descriptions in the UFSAR and the Process Control Program, and to assess the material condition and operability of the systems. The inspectors reviewed the current processes for transferring waste resins into transportation containers to determine if appropriate waste stream mixing and sampling procedures were utilized. The inspectors also reviewed the methodologies for waste concentration averaging to determine if representative samples of the waste product were provided for the purposes of waste classification in accordance with 10 CFR 61.55. During this inspection, the licensee was not conducting waste processing.

b. Findings

No findings of significance were identified.

.2 Waste Characterization and Classification

a. Inspection Scope

The inspectors reviewed the licensees radiochemical sample analysis results for each of the licensees waste streams, including dry active waste, resins, and filters. The inspectors also reviewed the licensees use of scaling factors to quantify difficult-to-measure radionuclides (e.g., pure alpha or beta emitting radionuclides). The reviews were conducted to verify that the licensees program assured compliance with 10 CFR 61.55 and 10 CFR 61.56, as required by Appendix G of 10 CFR Part 20. The inspectors also reviewed the licensees waste characterization and classification program to ensure that the waste stream composition data accounted for changing operational parameters and thus remained valid between the annual sample analysis updates.

b. Findings

No findings of significance were identified.

.3 Transportation Records

a. Inspection Scope

The inspectors reviewed six non-exempted package shipment manifests completed in years 2001 and 2002 to verify compliance with NRC and Department of Transportation requirements (i.e., 10 CFR Parts 20 and 71 and 49 CFR Parts 172 and 173). The licensee did not have any non-exempt package preparation or shipping underway during the inspection.

b. Findings

No findings of significance were identified.

.4 Identification and Resolution of Problems

a. Inspection Scope

The inspectors reviewed the most recent Nuclear Oversight Quality Assurance audit of the Radioactive Waste and Transportation Programs, along with departmental Focused Area Self-Assessments of the Radioactive Waste and Transportation Programs to evaluate the effectiveness of the self-assessment process to identify, characterize, and prioritize problems. The inspectors also reviewed corrective action documentation to verify that previous radioactive waste and radioactive materials transportation related issues were adequately addressed. The inspectors also selectively reviewed year 2001 and 2002 Condition Reports (CRs) that addressed radioactive waste and radioactive materials transportation program deficiencies, to verify that the licensee had effectively implemented the corrective action program.

b. Findings

No findings of significance were identified.

4OA2 Identification and Resolution of Problems

a. Inspection Scope

During this inspection, the inspectors reviewed corrective actions associated with the following issue to verify the effectiveness of the licensees corrective actions:

• Adverse Trend in Human Performance Errors Attributes considered during the review included the following:

• Complete and accurate identification of the problem in a timely manner commensurate with its significance and ease of discovery.

• Evaluations and disposition of performance issues associated with maintenance effectiveness.

• Consideration of extent of condition, generic implications, common cause, and previous occurrences.

• Classification and prioritization of the resolution of the problem commensurate with its safety significance.

• Identification of root cause and contributing causes of the problem.

• Identification of corrective actions which are appropriately focused to correct the problem.

• Completion of corrective actions in a timely manner commensurate with the safety significance of the issue.

b. Findings

No findings of significance were identified.

4OA3 Event Followup

a. Inspection Scope

The inspector reviewed the circumstances surrounding an inadvertent entry into Region B of the power-to-flow map which occurred during a Unit 2 rod pattern adjustment on November 10, 2002.

b. Findings

Introduction One Green finding and an associated violation of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, was identified following an inadvertent entry into Region B of the Unit 2 power-to-flow map during a control rod maneuver on November 10, 2002.

Description On November 10, 2002, during power ascension from LaSalle Maintenance Outage L2P02, a control rod maneuver was performed as part of the process to achieve the final target control rod pattern. Unit 2 was reduced in power to about 700 Megawatts Electric (MWe) to perform the required control rod maneuvers. Control rods associated with three arrays were sequentially withdrawn. Before withdrawing each array, the powerplex predictor was used to predict the conditions that would result from withdrawing the array. Powerplex predicted that following the withdrawal of the fourth and final array, that approximately a 2 percent margin would exist between actual core conditions and the power-to-flow map Region B limit of 109 percent flow control line.

Following withdrawal of the final array, a nuclear engineer submitted a powerplex case to confirm that the core response was within the preconditioning limits. Following a review of those results, the operating crew determined that Unit 2 had entered Region B of the power-to-flow map; a restricted region requiring an immediate exit due to power stability concerns. The last array withdrawn was re-inserted to its previous position and Region B of the power-to-flow map was confirmed to have been exited.

The licensee conducted a root cause evaluation which identified a number of programmatic and human performance deficiencies. These deficiencies included the following:

• Inadequate communication and implementation of changes in operational strategies as a result of changes in the fuel pre-conditioning rules which resulted in weak worker knowledge for monitoring near Region B of the power-to-flow map.

• Insufficient guidance for predicting core response to reactivity changes.

• Weaknesses in operator knowledge regarding the impact and monitoring of core parameters following rod maneuvers below Region B of the power-to-flow map.

• Use of inadequate indications for monitoring reactor power and flow during operation near Region B of the power-to-flow map.

• Failure to use all available tools, such as OD3 (heat balance) results and the electronic power-to-flow map on the computer, as rods were withdrawn.

• Inadequate pre-job briefing prior to the reactivity changes which failed to discuss the use of the power-to-flow map, proper communication between the Qualified Nuclear Engineer (QNE) and Operations, and roles and responsibilities.

The root cause investigation also determined that a previously unidentified entry into Region B occurred during a planned power maneuver. A review of the powerplex data during power maneuvers for both units, following implementation of the revised pre-conditioning limits, indicated Region B had been entered on Unit 2 on September 1, 2002. The September 1 entry was determined to be due to the same causes as the November 10, 2002 entry.

Analysis The inspectors determined that the issue described above constituted a finding as defined by the Reactor Oversight Process (ROP) since the issue was related to a licensee performance deficiency. In this case, the issue resulted in not meeting the licensee requirement to operate outside Region B of the power-to-flow map which was within the licensees ability to foresee, and which should have been prevented.

The inspectors reviewed this issue against the guidance contained in Appendix B, Issue Dispositioning Screening, of Inspection Manual Chapter (IMC) 0612, Power Reactor Inspection Reports. The inspectors compared this finding to the findings identified in Appendix E, Examples of Minor Issues, of IMC 0612 to determine whether the finding was minor. Following that review, the inspectors determined that the examples provided in Appendix E did not fit the specific situation being reviewed. As a result, the finding was reviewed against the questions in Section C, Minor Questions, of Appendix B to IMC 0612. During the review of this finding against Question 4, Is the finding associated with one of the below cornerstone attributes and does the finding affect the associated cornerstone objective?, the inspectors determined that the finding was associated with the configuration control, procedure quality, and human performance attributes of the barrier integrity cornerstone. The inspectors also determined that the finding affected the cornerstone objective of providing reasonable assurance that physical design barriers (e.g. fuel cladding) protect the public from radionuclide releases caused by accidents or events since operation outside established operational limits, such as the power-to-flow map, can lead to a violation of thermal limits and fuel cladding damage. As a result, the inspectors concluded that the finding was more than minor.

As a result, the inspectors reviewed this finding against the questions continued in Section C, SDP Questions, to Appendix B, Issue Dispositioning Screening, of IMC 0612. The inspectors determined that since the finding was associated with the Barrier Integrity cornerstone and the finding was associated with the integrity of fuel cladding, that the finding could be evaluated using the SDP. Utilizing the SDP Phase 1 Screening Worksheet for IE [Initiating Events], MS [Mitigating Systems], and B [Barrier Integrity] Cornerstones, the inspectors determined that since the issue involved the fuel barrier of the Reactor Coolant System, that in accordance with the screening worksheet the issue screened out as Green.

Enforcement 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, requires that conditions adverse to quality, such as deficiencies and deviations, be promptly identified and corrected. The failure to identify a September 1, 2002, Unit 2 entry into Region B of the power-to-flow map until November 2002 was an example where the requirements of 10 CFR 50, Appendix B, Criterion XVI, were not met and was a violation. However, because of its low safety significance and because it was entered into the corrective action program, the NRC is treating this issue as a Non-Cited Violation (NCV 50-373/0206-02(DRP); 50-374/0206-02(DRP)), in accordance with Section VI.A.1 of the NRCs Enforcement Policy. The issue was entered into the licensees corrective action program as Condition Report (CR) 130964.

4OA6 Meetings

.1 Exit Meeting Summary

The inspectors presented the inspection results to Mr. G. Barnes and other members of licensee management at the conclusion of the inspection on January 3, 2003. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

.2 Interim Exit Meetings

Interim exits were conducted for:

• Access Control, Radiation Material Processing and Transportation inspection with Mr. G. Barnes on November 8, 2002.

• Radioactive Material Processing and Shipping inspection with Mr. G. Barnes on November 15, 2002.

• Inservice Inspection with Mr. G. Barnes on December 18, 2002.

4OA7 Licensee Identified Violations

The following violation of very low safety significance (Green) was identified by the licensee and is a violation of NRC requirements which meets the criteria of Section VI of the NRC Enforcement Manual, NUREG-1600, for being dispositioned as an NCV.

Cornerstone: Occupational Radiation Exposure

Technical Specification 5.4.1 requires, in part, that the licensee establish and implement procedures covering activities recommended in Regulatory Guide 1.33 (Revision 2),

Appendix A, February 1978. The Regulatory Guide recommended procedures included radiation protection procedures for access control. Radiation protection procedures require that an area with radiation levels of 1000 mrem/hour or greater be locked and posted as a locked high radiation area, which did not occur for several hours in the Unit 1 Cooler/Condenser Room of the Off Gas Building on February 11-12, 2002. The problem is described in CR 00094760 and its associated apparent cause evaluation report. There were no unauthorized entries into the Cooler/Condenser Room while it was not properly controlled or posted and since area radiation levels coupled with the duration of the problem precluded a substantial potential for an overexposure, the issue was determined to be of very low safety significance. Consequently, it is being treated as an NCV (50-373/0206-03(DRP)).

KEY POINTS OF CONTACT Licensee Personnel G. Barnes, Site Vice President S. Landahl, Station Manager T. Connor, Design Engineering Supervisor D. Czufin, Site Engineering Manager D. Enright, Operations Manager F. Gogliotti, System Engineering Manager K. Hobbs, Radiation Protection Manager G. Kaegi, Regulatory Assurance Manager A. Kochis, ISI Coordinator C. Wilson, Station Security Manager NRC Personnel E. Duncan, Senior Resident Inspector D. Eskins, Resident Inspector D. Jones, Reactor Engineer M. Mitchell, Radiation Specialist W. Slawinski, Senior Radiation Specialist D. Wrona, Reactor Engineer J. Yesinowski, Illinois Department of Nuclear Safety ITEMS OPENED, CLOSED, AND DISCUSSED Opened 50-373/374/0206-01 URI Missing ECCS Area Cooler Screws 50-373/374/0206-02 NCV Entry Into Region B of the Power-To-Flow Map 50-373/0206-03 NCV Uncontrolled High Radiation Area Closed 50-373/374/0206-02 NCV Entry Into Region B of the Power-To-Flow Map 50-373/0206-03 NCV Uncontrolled High Radiation Area Discussed None LIST OF ACRONYMS AEER Auxiliary Electric Equipment Room ALARA As-Low-As-Reasonably Achievable APRM Average Power Range Monitor ASME American Society of Mechanical Engineers ATWS Anticipated Transient Without Scram CR Condition Report CRD Control Rod Drive CST Condensate Storage Tank DRP Division of Reactor Projects DRS Division of Reactor Safety EC Engineering Change ECCS Emergency Core Cooling System EDG Emergency Diesel Generator EHC Electro-Hydraulic Control ENS Emergency Notification System FCV Flow Control Valve FW Feedwater HPCS High Pressure Core Spray IMC Inspection Manual Chapter IPA Infrequently Performed Activity ISI Inservice Inspection LFP LaSalle Fuel Procedure LOS LaSalle Operating Surveillance LSH Lake Screenhouse LST LaSalle Special Test LTS LaSalle Technical Surveillance MT Magnetic Particle Testing MWe Megawatts Electric NCV Non-Cited Violation OC Operator Challenge OE Operability Evaluation OWA Operator Workaround PMT Post-Maintenance Test PT Penetrant Testing QNE Qualified Nuclear Engineer RCIC Reactor Core Isolation Cooling RCS Reactor Coolant System RHR Residual Heat Removal RHRSW Residual Heat Removal Service Water ROP Reactor Oversight Process RPS Reactor Protection System RPV Reactor Pressure Vessel RR Reactor Recirculation RWLCS Reactor Water Level Control System SDP Significance Determination Process LIST OF ACRONYMS (cont)

SRV Safety Relief Valve SSC Structure, System, or Component TCV Turbine Control Valve TDRFP Turbine-Drive Reactor Feedwater Pump UFSAR Updated Final Safety Analysis Report URI Unresolved Item UT Ultrasonic Testing VC Control Room Ventilation VDC Volt Direct Current VE Auxiliary Electric Equipment Room Ventilation VX Essential Switchgear Room Ventilation WO Work Order LIST OF

DOCUMENTS REVIEWED

Adverse Weather Protection

LOS-ZZ-A2 Preparation for Winter/Summer Operation Revision 24

Equipment Alignment

LOP-HP-2M Unit 2 HPCS System Mechanical Checklist

LOP-HP-2E Unit 2 HPCS System Electrical Checklist

LOP-RH-2M Unit 2 B RHR System Mechanical Checklist

LOP-RH-3M Unit 2 C RHR System Mechanical Checklist

LOP-RH-4E Unit 2 B/C RHR System Electrical Checklist

LOP-RHRSW-2BM Unit 2 B RHRSW System Mechanical Checklist

LOP-RHRSW-3E Unit 2 B RHRSW System Electrical Checklist

Fire Protection

Updated Final Safety Analysis Appendix H Revision 13

Report

Inservice Inspection

MT-EXLN- Procedure for Magnetic Particle Examination Using January 5, 2002

2V0 AC Yoke, Dry Powder, or Wet Visible

PT-EXLN-104V0 Procedure for Liquid Penetrant Examination Color January 5, 2002

Contrast (Visible) Solvent Removable

GE-UT-311 Procedure for Manual Ultrasonic Examination of January 5, 2002

Nozzle Inner Radii and Bore

GE-PDI-UT-1 PDI Generic Procedure for the Ultrasonic January 5, 2002

Examination of Ferritic Piping Welds

GE-PDI-UT-2 PDI Generic Procedure for the Ultrasonic January 5, 2002

Examination of Austenitic Pipe Welds

ISI Program Second Ten-Year Inspection Interval, LaSalle December 14,

Plan County Nuclear Power Station, Units 1 and 2 2001

CR 135708 Liquid Penetrant Examination Report Discrepancy

Attachment

Operator Licensing Requalification

ESG 50 CRD FCV Setpoint Failure/TDRFP Turbine Lube Oil Leak/Heater Revision

String Isolation/Loss of Stator Cooling/5-Rod ATWS 0

ESG47 RWLCS Trouble/Loss of RPS A/APRM C Failure/Loss of Both Revision

RR Pumps/Failure to Automatic Scram/K SRV Leakage/RHR Heat 0

Exchanger Tube Rupture

Maintenance Risk Assessment and Emergent Work Evaluation

LaSalle 7-Day Look- Various

Ahead Schedule

WO00490705 Change Control Power Fuse for 1AP76E-F3-F October 1, 2002

EC338741 Change Control Power Fuse for 1AP76E-F3-F September 24, 2002

LaSalle 3-Day Look- Various

Ahead Schedule

Personnel Performance During Nonroutine Plant Evolutions

Drawing 1E-0-4432AG Control Room HVAC System VC - Part 7 Revision P

Drawing 1E-0-4432AX Control Room HVAC System VC - Part 22 Revision J

Drawing 1E-0-4432AJ Control Room HVAC System VC - Part 9 Revision T

Drawing 1E-0-4432AM Control Room HVAC System VC - Part 12 Revision J

Drawing 1E-0-4432BD Control Room HVAC System VC - Part 28 Revision E

Drawing 1E-0-4432AL Control Room HVAC Alarms System VC - Part 11 Revision H

Drawing 1E-0-4432BF Control Room HVAC System VC - Part 30 Revision Q

Drawing 1E-0-4432BH Control Room HVAC System VC - Part 32 Revision B

Drawing 1E-0-4432AW Control Room HVAC System VC - Part 21 Revision F

Drawing 1E-0-4432AU Control Room HVAC System VC - Part 19 Revision E

Drawing 1E-0-4432AN Control Room HVAC System VC - Part 13 Revision N

Drawing 1E-0-4432AH Control Room HVAC System VC - Part 8 Revision P

LFP-400-6 Installation and Operation of Sipping Equipment Revision 6

LFP-400-1 Fuel and Nuclear Component Movements Within Revision 23

the Reactor and Spent Fuel Storage Pools

Attachment

LST-2002-034 2B Diesel Generator Voltage Regulator PMT Revision 0

CR 127728 2B Voltage Regulator Very Erratic October 16,

2002

IPA Briefing Sheet 2B Diesel Generator Voltage Regulator PMT Revision 0

WO 498416-01 Replace 2B Diesel Generator Voltage Regulator

Vendor Manual J-157 Basler Diesel Generator Voltage Regulator

EC 339411 Division 3 EDG Testing Assessment With Unit 2 in Revision 1

Mode 1

EC 339388 Failed Fuel Vacuum Sipping Equipment Revision 0

Operability Evaluations

OE02-12 Unit 1 Turbine Control Valve (TCV) #1 Foreign Material Revision 0

CR00120773 Unit 1 #1 Turbine Control Valve Strainer Plugged August 27,

2002

CR00120659 Prompt Investigation Report - Unit 1 #1 Turbine Control Revision 0

Valve Strainer Plugged

EC339629 Unit 2 Safety Relief Valve (SRV) Piping Supports Revision 0

Pinned

Dwg M-900 Main Steam Piping Sheet 19

Dwg M-900 Main Steam Piping Sheet 10

Dwg M09- Support MS04-2604C Sheet 1

MS04-2604C

Dwg M09- Support MS04-2605C Sheet 1

MS04-2605C

Dwg M-900 Main Steam Piping Sheet 24

OE02-04 Unit 1 Main Steam Isolation Valve Limit Switches Revision 1

Operator Workarounds

Operator Workaround October 2, 2002

List

Operator Challenge 238 Emergency Diesel Generator Relief Valve October 2, 2002

Sticking

Attachment

Post-Maintenance Testing

WO00468913 Replace Cell #23 For Unit 2 Division 2 125

VDC Battery

LEP-DC-02 Individual or Multiple Battery Cell Performance Revision 12

Test

LEP-DC-03 Individual Battery Cell Modified Performance Revision 0

Test

LEP-DC-04 Installation of Division 2 Batteries Revision 12

CR L2000-04873 Station Battery Evaluation August 31, 2000

CR 129595 Foreign Material Noted in Several Battery Cells October 30, 2002

LES-DC-101B Division 2 125 Volt Battery Inspection for Units Revision 10

and 2

Refueling and Outage Activities

LFP-400-1 Fuel and Nuclear Component Movements Within the Revision 23

Reactor and Spent Fuel Storage Pools

L2P02 Shutdown Safety Management Program October 8, 2002

EC 339413 Evaluate the Use of Spent Fuel Pool Cooling as an Revision 0

Alternate Decay Heat Removal Source for Shutdown

Safety

EC 339466 Unit 2 Spent Fuel Pool Cooling System Heat Removal Revision 0

Capacity

NF0200148 LaSalle Unit 2 Cycle 9A Design Basis Loading Plan Revision 0

NF0200149 L2C9A Fuel Move Sequence to Replace Failed Fuel Revision 0

Assemblies and Beginning of Cycle Shutdown Margin

PORC 02-30 Plant Onsite Review Committee (PORC) Approval of Revision 0

LaSalle Unit 2 Restart From L2P02

DCP RPV Cavity Grating, Ladder, and Insulation Frame October 21, 1999

9900210 Bolting Modifications

LGP-1-1 Normal Unit Startup Revision 68

LOP-FW-04 Startup of Turbine Driven Reactor Feed Pump Revision 36

(TDRFP)

LOP-RL-01 Operation of the Reactor Water Level Control System Revision 16

Attachment

Surveillance Testing

LOS-DG-M2 1A(2A) Diesel Generator Operability Test Revision 52

LTS-200-19, Att. ECCS Cubicle Area Cooler Flowrate Test - Unit 2 HPCS Revision 9

B Area Cooler

M-1366 Sheet 2 Unit 2 Reactor Building Ventilation System - 694 Revision F

LTS-200-19, Att. ECCS Cubicle Area Cooler Flowrate Test - Unit 2 HPCS June 1, 2001

B Area Cooler

Emergency Action Level and Emergency Plan Changes

LaSalle Station Annex to Exelons Standardized Emergency Plan Revision 11

LaSalle Station Annex to Exelons Standardized Emergency Plan Revision 12

LaSalle Station Annex to Exelons Standardized Emergency Plan Revision 13

Identification and Resolution of Problems

HU-AA-101 Human Performance Tools & Verification Practices October 31, 2001

HU-AA- Pre-Job, Heightened Level of Awareness, Infrequent Plant July 29, 2002

211 Activity & Post Job Briefings

Exelon Nuclear Human Performance Baseline September 23,

Assessment 2002

Exelon Nuclear Human Performance Baseline March 14, 2002

Assessment

LaSalle Station Human Performance Review - July 2002 August 28, 2002

LaSalle Station Human Performance Review - August October 4, 2002

2002

Event Followup

CR 132370 Powerplex Indication of Entry Into November 19, 2001

Region B - Extent of Condition

Prompt Unplanned Entry Into Region B of the

Investigation Report Power-to-Flow Map

CR 103964 Unplanned Entry Into Region B of the November 10, 2002

Power-to-Flow Map

Attachment

Root Cause Report Unplanned Entry Into Region B of the

Power-to-Flow Map

LOA-RR-201 LaSalle County Station Power-to-Flow Revision 0

A Map

Reactivity Maneuver LaSalle Unit 2 - Withdrawal of Array Cycle 9A

(ReMa) Form 10B Rods

LAP-100-35 Reactivity Management Controls Revision 12

Access Controls For Radiologically Significant Areas

RP-AA-222 Methods For Estimating Internal Exposure From In Revision 1

Vivo and In Vitro Bioassay Data

RP-AA-350 Assessment of Radiologically Contaminated Revision 0

Personnel

RP-AA-400 ALARA Program Revision 2

RP-AA-401 Operational ALARA Planning and Controls Revision 2

RP-AA-605 10 CFR 61 Program Revision 0

CR 130190 Individual Not Following Radiologically Controlled November 4, 2002

Area Egress Procedure

CR 130198 Observed Individuals Deconning Themselves November 2, 2002

Without Radiation Protection Technician Help

CR 130270 Individual Not Monitoring Properly at Radiologically November 4, 2002

Controlled Area Egress

CR 130412 Contamination of Unit 2 820 Reactor Building November 6, 2002

During Backwash of 2B Reactor Water Cleanup

Filter

Radioactive Material Processing and Transportation

RW-AA-100 Process Control Program for Radioactive Wastes Revision 2

RP-AA-600 Radioactive Material/Waste Shipments Revision 5

LAP-100-27 Guidelines for Radioactive Waste/Material Revision 22

Shipments

LOP-WX-26 Dry Active Waste Sorting For Radioactive Waste Revision 0

Packaging and Compaction

Attachment

LOP-WX-29 Loading of Radioactive Waste Shipments Using Revision 5

High Integrity Containers

Report 01-071 2000 Annual Radioactive Effluent Report and April 30, 2001

Triannual Chlorine Survey Report

NOA-LS-01-3Q Nuclear Oversight Continuous Assessment Report October 25, 2001

LaSalle Station July-September, 2001

Memorandum LaSalle Station Focus Area Self Assessment on October 21, 2002

Radioactive Material Shipping

Memorandum Focus Area Self-Assessment on Radwaste Material July 2, 2002

Condition/Equipment Reliability

CR 00082954 Inadequate Planning for Rad Material Shipment June 25, 2002

(SRVs)

CR 00085525 Inadequate Pre-Planning for CRD Shipment December 5, 2001

CR 00091013 Failure to Follow the CRD Shipping Schedule January 17, 2002

CR 00092513 Inadequate Communication Resulted in Delay of January 25, 2002

Radioactive Material Shipment

CR 00094766 Inadequate Planning for Radioactive Material February 11, 2002

Shipment

CR 00098690 Shipping/Shipper Qualifications Not Tracked Using March 11, 2002

PQD

CR 00114692 Delays in Electro-Hydraulic Control Fluid Sample July 8, 2002

Transfer

CR 00109212 PQD Implementation-DTC Concerns November 11,

2001

CR 00111958 RW Solids Manager Has Not Completed June 14, 2002

Qualification Cards for Shipping

CR 00112133 Qualifications Tracking Deficiency/Focused Area February 20, 2002

Self-Assessment Documentation Condition Report

1. 1

CR 00123259 Inadequate Drum Sealing Ring for Department of September 17,

Transportation 7A Type A Container 2002

CR 00127988 Radioactive Waste Manifest Software Error October 15, 2002

CR 00129968 Unplanned Radioactive Material Shipment October 31, 2002

CR 00113516 Inadequate Number of 4-Digit Orange Panels for June 25, 2002

Radioactive Material Shipment

Attachment

CR 00114141 Radwaste Shipment Issue June 28, 2002

CR 00118691 Rad Waste Shipment Arrived at Wrong Destination August 8, 2002

CR L2001- ALPS Area of Radwaste Truckbay Found May 12, 2001

2870 Contaminated

CR L2001- Radwaste Shipping Cask Gasket Failure June 5, 2001

295

CR L2001- Radwaste Discussion of Byron Event June 22, 2001

03728

CR L2001- Identified Safety Issue August 23, 2001

04878

CR 00113070 2A Phase Separator Transfer Loop Problems June 24, 2002

CR 00130752 NRC Identified Radwaste IRSF Log Procedure November 6,

Adherence Issue 2002;

LW01-13 Radwaste Shipment Documentation Package

LW01-27 Radwaste Shipment Documentation Package

LW01-28 Radwaste Shipment Documentation Package

LW02-08 Radwaste Shipment Documentation Package

LW02-16 Radwaste Shipment Documentation Package

LW02-17 Radwaste Shipment Documentation Package

Attachment